In our mortgage area, we have a 2nd review process that takes place within 30 days of denial.
Once the review is completed, the AAN is mailed out and dated the date of the 2nd review / mail date.
This is also the date that flows to the HMDA LAR for action taken date.
Sometimes this can be up to 45 - 60 days from application date.
Is this ok?
Would it give an examiner a cause to look closer as to why we are taking so long when under the regulation it appears to be allowed.

Maybe I am thinking too much. It is a Monday.

When is the customer advised of the denial? That is the date you need.

Also, are you counting from initial application or completed application?

A process could be:

Application received (incompleteness), starts to go through process
Notice of incomplete application issued day 10, Reg B clock stops
Needed information provided day 25 from initial ap, ap is now complete -financial institution has 30 days to make decision and notify customer.
Final decision made day 15 from completed ap, which is 40 days from initial ap.